2012 Methods Update Rule (MUR)

Information Notice Concerning the 2012 EPA Final MUR

On May 18, 2012, EPA promulgated changes to the list of Clean Water Act (CWA) methods at 40 CFR Part 136.3. This action, referred to as the Methods Update Rule (MUR), approves new methods or changes to existing methods, that affects over 100 EPA methods, Standard Methods, ASTM methods, and other test procedures in Part 136 of Title 40 of the Code of Federal Regulations (CFR). The final rule may be found at:

Will an amendment to certification be required?

FIELD LABS

Field labs will not be required to fill out a new application since there are no major changes in the field method procedures. These certificate attachments will be automatically updated to the approved methods with the 2013 certification attachment. The approved procedures for field analyses will be updated shortly and placed on the Laboratory Certification website. No further actions are required of Field Laboratories at this time.

NON-FIELD LABS

It is our goal to send an updated application to each laboratory, probably in August, requesting you to update to the new approved methods. Your new certification attachment for 2013 will reflect the currently approved methods. Guidance for implementation is offered below.

Effect on your laboratory

The Final Methods Update Rule:

· Allows only one approved revision of a method to be used for testing under 40 CFR 136.

· Includes new standardized quality assurance and control requirements.

Each laboratory will need to review the MUR and evaluate its effect on current laboratory practices.Some laboratories will need to change to a newer revision of Standard Methods, ASTM or other methods. Many laboratories will need to change to a different naming format for Standard Methods methods even though their actual procedure may not change. These changes must be made in the laboratory’s Standard Operating Procedures and in Quality Manuals, as well as any other place where the method is cited, e.g., reports, benchsheets, logs, etc.

New methods naming convention

One major change with this MUR is the format for referencing methods in Standard Methods has changed significantly. The old system of referencing by editions of Standard Methods is no longer used. Instead the methods are reference by year (i.e., the year approved by Standard Methods Committee). For example, instead of BOD being referenced as SM 18th Edition 5210 B (multiple Editions were approved), the only approved method now is referenced as 5210 B – 2001. The approved date may be found by checking the footnote on the method introduction, as illustrated below:

* Approved by Standard Methods Committee, 2001.

Joint Task Group: James C. Young (chair), George T. Bowman, Sabry M.

Kamhawy, Terry G. Mills, Marlene Patillo, Ray C. Whittemore.

In this example, the approved BOD method may be found in either the 21st or 22nd Editions, or on line. You may notice that some methods in the 22nd Edition of Standard Methods have editorial revision dates in addition to the Standard Methods Committee approval date. Refer only to the Standard Methods Committee approval date when determining whether the method is approved.

If you are currently using an older edition of Standard Methods (e.g., 18thEdition) that does not include the approved methods, purchasing the 22nd Edition will cover most approved methods or purchasing the online subscription will cover all.

Implementation schedule

Due to the level of effort needed to transition all laboratories to update their quality systems to the approved methods defined by the MUR, the North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) program will be asking certified laboratories to move toward implementation of the new rule immediately, with changes fully implemented by the end of 2012.

First Steps

Laboratories are encouraged to start immediately by:

1. Reviewing the scope of certification, and determine if the methods used are approved under the MUR.

2. Where the laboratory currently has a certified method which is not approved under the MUR, the laboratory has two choices:

a. Use the newer revision of the method approved under MUR and implement changes necessary, including updates to the SOP and Quality Manual, to comply with the requirements of the MUR method in the laboratory’s processes. For example, a laboratory may change from SM 2320 B, 18th edition for alkalinity to SM 2320 B-97.

b. Withdraw the certification or accreditation for the method that is not approved under the MUR and implement a different approved method. For example, a laboratory may change from SM 2320 B, 18th edition for alkalinity to ASTM D-1067-06.

3. Where a different method technology is adopted, method validation and start-up requirements (e.g., MDLs, IDOCs, PTs, etc.) may apply.

When will I receive an updated certificate?

Just as laboratories will have to make changes due to the requirements of the MUR, NC WW/GW LC will have significant changes to make too. This primarily involves converting the current database method naming conventions to the new Standard Methods nomenclature and to adding newly approved tests. The transition period will allow both the laboratories and the regulatory agencies time to respond to these updates. Updated or revised certificates will be provided on schedule with the next certification cycle beginning on January 1, 2013.

Inspection report references

During this transition period, inspection reports will refer to the methods employed at the laboratory at the time of the inspection, but will reference the requirements in the most recently approved version of the method. Any difficulties encountered with meeting the requirements of these references by the date due may be addressed in the written corrective action response.